FinCEN Provides Guidance on Convertible Virtual Securities

Adam Witmer
Regulatory Update, BSA

On May 9, 2019, FinCEN issued two different pieces of guidance relating to virtual currency.  The first issuance is guidance titled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies,” also known as FIN-2019-G001.  This first guidance was issued in response to questions raised by stakeholders concerning the regulatory treatment of multiple variations of businesses dealing in convertible virtual currencies.

The second issuance was an Advisory (FIN-2019-A003) on Illicit Activity Involving Convertible Virtual Currency.  This advisory was issued to assist financial institutions in identifying and reporting suspicious activity related to criminal exploitation of convertible virtual currencies for money laundering, sanctions evasion, and other illicit financing purposes.   The advisory highlights a number of things related to convertible virtual currency such as red flags and information that would be most valuable to law enforcement.

FIN-2019-G001 can be found here.  

FIN-2019-A003 can be found here.

Adam Witmer
Regulatory Update, BSA
Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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